Submission to the Department of Employment Affairs and Social Protection on their Statement of Strategy 2020-2023 - October 2020
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October 2020 Submission to the Department of Employment Affairs and Social Protection on their Statement of Strategy 2020-2023
Introduction
Founded in 1973, the National Women’s Council (NWC) is the leading national women’s membership
organisation. We represent and derive our mandate from our membership, which includes over 190
groups and organisations from a diversity of backgrounds, sectors and locations across Ireland. Our
mission is to lead and to be a catalyst for change in the achievement of equality for women. Our vision is
of an Ireland and of a world where women can achieve their full potential and there is full equality for
women. NWC acknowledges the intersectionality of women’s lived experiences and in particular seeks to
end discrimination on the grounds of gender, family status, religion, race, age, sexual orientation, marital
status, disability, ethnicity or membership of the Travelling community.
NWC welcomes the opportunity to make a submission on DEASP’s strategy for 2020-2023. The
development of this new strategy comes at a crucial juncture and it must include a plan to address the
inequalities highlighted and reinforced by COVID-19. The Department holds responsibility for ensuring
social inclusion, addressing poverty and supporting people back into work and as such, it will play a key
role in driving our recovery and in shaping it. The focus for DEASP’s strategy for the next three years must
be on reforming our work and welfare systems so that they are capable of addressing the needs of
diverse women in a post COVID-19 world and ensuring its policy and budgetary decisions are gender and
equality proofed.
Embed Gender and Equality proofing
Budget 2021 provides an allocation of €25.13bn for DEASP in 2021, the largest budget provided to any
government department. Given the significance of this funding, and the role of DEASP in addressing
poverty, pensions reform and labour market activation, it is particularly important that DEASP engage in
comprehensive gender and equality proofing of policy and budgetary decisions. Effective gender
budgeting must consider how intersecting oppression and discrimination impacts on women’s
experiences of a policy or budgetary decision.
Despite commitments to gender and equality proofing in a range of government policies, key DEASP
policies produced in recent years, such as the Roadmap for Social Inclusion and pensions reforms such as
Auto-enrollment do not provide evidence of gender proofing. While there is currently no statutory
obligation on government departments to carry out gender and equality proofing, the OECD have
included this is its recommendations to Ireland1 and DEASP has an obligation to actively promote equality
under the Public Sector Duty.
NWC recommends
• Ensure that all new policies, strategies and investments are gender and equality proofed,
including proposed pension reforms.
• Carry out a gender and equality proofing exercise as part of the mid term review of the Roadmap
for Social Inclusion
• Task the proposed Commission on Taxation and Social Welfare with:
- Carrying out a review of all individual and sectoral tax expenditures, assessing their cost and
gender and equality impacts
- Examining how employers PRSI can be increased to fund social infrastructure
1 https://www.oecd.org/gov/budgeting/equality-budgeting-in-ireland.pdf
NWC submission to DEASP on Statement of Strategy 2020-2023 1Ensure active labour market policy works for women
The Irish social welfare system was built for a different era on a largely male breadwinner understanding
of both the labour market and social welfare systems. Eligibility for Jobseekers payments requires women
with care responsibilities to prove that they can cover childcare needs, can work full time and are looking
for full time work. Failure to satisfy these conditions means that women cannot establish an individual
right to payment or to access education, training and employment opportunities. As we go into a period
with record unemployment rates, it is important to remember that the current system has not been as
effective at lowering female unemployment as male unemployment, with more women on the Live
Register in February 2020 than February 2007.
Our Shared Future commits to a jobs-led recovery, to improve jobseeker supports for people aged under
24, to provide return ships to support women who have taken time out of work to raise their families and
to specific targets for the uptake of apprenticeships by women, people with disabilities and
disadvantaged groups.
NWC recommends
• Invest in care as a key element of ALMP including development of training and professional salary
scales. Care jobs are also green jobs.
• Develop a new gender and equality proofed labour market activation plan to address the challenges
of working and living with COVID-19
- Ensure it provides supports to those not currently in receipt of Jobseeker’s payments, e.g
qualified adults
- Provide targeted supports to those furthest from the jobs market including carers and disabled
women, e.g embed Job Coaches in all Intreo offices to support disabled people to obtain and
retain employment
- Develop a fully gender proofed national Traveller employment strategy as part of the
mainstream strategy to take account of barriers to participation of Traveller women
- Examine the role that a Participation Income could play in reforming our work and welfare
system
• Gender and equality proof new labour activation initiatives and review their gender impact before
scaling up
- Ensure workers are not pressured to increase hours while maintaining care obligations
- Ensure no-one is required to accept insecure, non-fixed hour jobs as ‘reasonable offer of work’
- Recognise atypical work patterns by calculating unemployment on hours rather than days per
week
- Ensure jobs created as part of a green new deal are gender proofed
• End the limitation rule and promote administrative individualisation at first point of contact
• Commission a national survey to ascertain skills, education, health, care and employment experience
of qualified adults to address the data gaps on QA’s
Promote decent work
Ireland has one of the highest rates of low paid workers in the OECD, with 23% of the workforce
designated as low paid compared to an OECD average of 15%.2 The labour force is highly gender
segregated and the sectors in which women predominate, tend to be those that are lowest paid and
most precarious. While almost 70% of women are ‘essential’ workers, they are among the lowest paid in
the economy. Minimum wage workers are more likely to be female, young, migrants and those working
2 OECD (2019). Wage levels statistics. https://data.oecd.org/earnwage/wage-levels.htm
NWC submission to DEASP on Statement of Strategy 2020-2023 2part time3 and six in ten childcare workers earn below the Living Wage. There is also a significant and
growing gender pay gap.
NWC recommends
• Refocus the work of the LPC towards a living wage commission, as proposed in Budget 2021 and
actively champion a move towards the Living Wage as the minimum wage
- Make NWC a full member of the LPC/living wage commission
- Attach social criteria, clauses and conditionality to Employer incentive schemes and
advocate for government procurement processes to ensure living wage social clauses in key
sectoral procurement processes in female dominated sectors.
• Regularise the situation of migrant workers
• Commission an independent, gender and equality proofed study to capture the extent of casual
and bogus employment arrangements4
• Commission an up to date, independent nationwide study on the prevalence and nature of
pregnancy discrimination and disadvantage in the workplace
• Support collective bargaining as evidence shows that it is one of the most effective ways to
address the gender pay gap
Ensure work life balance and recognise care
COVID-19 has brought into the public domain the reality of the largely unpaid and invisible care economy
in which women dominate. It has also highlighted the inequalities of the distribution of care in our
society. Women continue to provide the majority of unpaid work and the choices women can make with
regard to employment are severely limited due to lack of a public early years and care infrastructure and
as men have not taken equal responsibility for care within families.
NWC recommends
• Increase the rate of maternity, paternity and parent’s benefit to €295 per week to bring more in
line with EU norms5
• Work with colleagues in DCDEI to increase the duration of paid parents leave to 26 weeks per
parent (or 52 weeks for lone parents), on a phased basis, to give parents choices in their child’s
first year
• Convert existing unpaid parental leave to paid leave
• Increase paid paternity leave to 4 weeks
• Resource a full & retrospective Homecare Credit that also acts as re-entry credit to access
training
• Introduce six paid days of carers' leave
• Work with colleagues to establish an All Party Oireachtas Committee to make recommendations
on the reorganisation of work, reduced working time and the 4 day week
• Commission a time use survey to gather updated data on time spent on unpaid work
• Work with colleagues to introduce legislation on flexible working to ensure that it is open to all
from day one in the job, unless there are significant business reasons why that is not possible
3
Redmond, P. (2020). Minimum wage policy in Ireland. ESRI.
4 As per the DEASP’s Roadmap for Social Inclusion 2020-2025
5
When the duration and value of paid leave across maternity, paternity and parental leave schemes is combined, Ireland lags behind our
EU peers. Germany for example, provides total paid leave for mothers of 58 weeks, payable at the equivalent of 73% of the average wage.
Ireland compares unfavourably with a combined 28 weeks of leave (26 weeks maternity, 2 weeks parental benefit) at 27% of the average
wage.
NWC submission to DEASP on Statement of Strategy 2020-2023 3• Though not under the remit of DEASP, the introduction of a universal, public childcare system is
a key enabler of work life balance, of women’s participation in the labour market and of gender
equality overall so NWC asks that DEASP work closely with colleagues in the Department of
Children, Disability, Equality and Integration on this.
End Poverty
The social welfare system plays an important role in reducing poverty and inequality. It should ensure
that everyone, no matter what their stage of life, can live free from poverty. While 14% of the overall
population was at risk of poverty in 2018, lone parents (86% of whom are women) continue to be among
those most at risk of poverty (34%). Disabled women and women from outside the EU are also more at
risk of poverty than the general population. Among those aged 65 and over, 15% of men and 25% of
women are at risk of poverty.
Budget 2021 made some targeted increases to certain payments but failed to increase core social welfare
payments. The increases in illness benefit and the setting of the PUP at a higher rate than job seekers
payments is an acknowledgement that social welfare rates are too low to maintain an adequate standard
of living for many.
NWC recommends
• Establish the MESL as the benchmark for social welfare payments
• Recognise the unique challenges that come with parenting alone by providing targeted supports
to lone parents such as allowing them to receive both the Jobseeker's Transitional payment and
Working Family Payment, reducing the requirement for Working Family Payment for lone
parents to 15hrs and excluding Working Family Payment from income assessment for differential
rental schemes
• Providing targeted supports to those most at risk of poverty by implementing a cost of disability
payment, increasing the income disregards for Carers Allowance, granting Child Benefit and
access to the Free Travel Scheme to those seeking asylum and restoring the full rate of
Jobseekers Allowance for 18-24 year olds.
Close the gender pensions gap
As women continue to do the majority of care work and are more likely to be in low paid, part time jobs,
it is difficult to collect sufficient PRSI contributions to be eligible for the full State contributory pension
and so women are more likely to be reliant on the non-contributory pension. Only 28% of women (55% of
men) of pension age have an occupational or private pension with women less likely to be able to afford
one and their employers less likely to offer one.6 Older rural women are even less likely than older urban
women to have an occupational or contributory pension.7 These factors culminate in a gender pension
gap of 35%.8 The Homemaker’s Scheme does not address the inequalities and discrimination experienced
by older women and those affected by the marriage bar.
Our Shared Future commits to maintaining the state pension as the bedrock of the system, introducing a
Total Contributions Approach, and examining options for a pensions solution for carers. Based on NWC’s
published research on pensions9, it is our view that introducing a universal State Pension system which
6 CSO (2020). Pensions statistics. https://www.cso.ie/en/releasesandpublications/ep/p-pens/pensioncoverage2019/
7 Ní Léime, A. et al. Gender and Rural Ageing in Ireland: Profile and Key Issues. Irish Centre for Social Gerontology National University of
Ireland, Galway
8 Nolan, A. et al (2019). Gender, pensions and income in retirement. Dublin: ESRI.
9
https://www.nwci.ie/download/pdf/pensions_publication_final.pdf
NWC submission to DEASP on Statement of Strategy 2020-2023 4will guarantee income adequacy in older age in the best way to achieve the commitments set out in the
programme for government. This can be paid for by ending tax relief on private pensions and investing
the savings in a first-tier state pension.
NWC recommends
• Task the proposed Commission on Pensions with examining how a universal pension could be
implemented by ending tax relief on private pensions and investing the savings in a first-tier
state pension
- Grant NWC membership of the Pensions Commission currently being established
• Ensure the Total Contributions Approach (TCA) is limited to 30 years for the maximum pension
and carry out a gender and equality impact assessment of TCA & Auto-enrolment
• Value care by delivering a full Homecarers credit that actively recognises the contribution of care
and also serves as a re-entry credit and ensure that women born before 1946 can access
• Following on from the Budget 2021 decision to defer the increase in pension age, resource a GIA
on projected increases in state pension age
Establish a Statutory Maintenance Service
There is a significant rate of non-compliance with child maintenance orders, significant delays in the
courts system and a high cost involved in engaging a litigious route. NWC welcomed the commitment in
Budget 2020 to addressing the issue of child maintenance. A Statutory Maintenance Agency would take
the issue of child maintenance out of the adversarial court system, reduce the burden on women to
litigate for child maintenance orders and act as an anti-poverty measure. It has also been called for by the
Joint Committee on Social Protection in its Report on the Position of Lone Parents in Ireland (2017) and
the UN Committee on the Elimination of All Forms of Discrimination Against Women.
NWC recommends
• Establish a Statutory Maintenance Authority
NWC submission to DEASP on Statement of Strategy 2020-2023 5You can also read
